United States Tax Court December 6, 1977, Docket No. 7740-74 (Estate of Morse v. Commissioner)

lead-opinion

Drennen, Judge:

Respondent has determined a $30,761.49 deficiency in the amount of Federal estate tax due from petitioner.

The principal issue presented is whether the present value of annual payments of $12,000 per year to the decedent’s surviving spouse is deductible by petitioner under section 2053(a)(3), I.R.C.